This document is designed to set the parameters for SFS’s remuneration policy and to ensure a consistency of approach in recruiting and retaining employees who will be engaged, appraised, trained and motivated to play a key part in SFS’s culture of treating their customers fairly.
This Policy statement aims to:
- Ensure that SFS’s remuneration policy is in line with its business strategy, objectives, values and long term interests
- Ensure that a consistent approach is taken to attract, develop, retain and reward employees for contributing to SFS’s success, whilst maintaining financial stability and robust and effective risk management
- Act as an aide-memoire for the relevant points to be covered
- Maintain the relevance of the policy by ensuring that reviews are carried out by the Directors at predetermined frequencies
1.2 Remuneration Code Principles
SFS is aware of the FCA’s Remuneration Code incorporating 12 principles and this policy sets out how it will act in accordance with them.
The Code applies to:
- Any person holding a controlled function
- Any person holding a role in the firm of senior management
- Any person who is considered a risk-taker (without needing director approval for their decisions)
- Any employee receiving total remuneration that takes them into the same remuneration bracket as senior management and risk-takers, whose professional activities have a material impact on the firm’s risk profile.
SFS has maintained a record of all employees to whom the Remuneration Code applies and it has taken steps to ensure that all employees to whom the Code applies understand the implications of their status and the potential for any remuneration that does not comply with the Code to be rendered void and recoverable by SFS.
1.3 Related Documents/Policies
- Pillar 3 Disclosure
- Compliance Manual
- Conflicts of Interest Policy
- Personal Account Dealing Policy
- Treating Customers Fairly Policy
- Contracts of Employment
2 RISK MANAGEMENT AND RISK TOLERANCE
SFS has assessed its risk appetite, which is reviewed annually and this is documented in the ICAAP which is available to all employees upon request. Operating within the scope of SFS’s risk appetite is an absolute pre-requisite to the award of any variable, incentive or performance related compensation.
Non-compliance or actions contrary to the stated risk appetite will not be rewarded.
Operating within the stated risk appetite is realised in practice through SFS’s Internal Capital Adequacy Assessment Process (“ICAAP”). The ICAAP is approved annually by SFS’s Board of Directors.
Included in the ICAAP, and considered in the awarding of variable compensation and commission are:
- Key risk indicators (“KRIs”) and tolerances set by the Board of Directors and assigned to business units and ‘Identified Staff’. KRIs are defined and measured annually in employee annual appraisals and reviewed on a six monthly basis;
- Clear risk objectives and the ongoing monitoring and supervision of performance for every employee;
- Compliance by all employees to the regulatory obligations under the Remuneration Code
SFS has ensured that this policy is in line with the agreed business strategy, objectives, values and long term interests of SFS and its clients.
3 CONFLICTS OF INTEREST
SFS ensures that this remuneration policy includes measures to avoid conflicts of interests. To demonstrate this, the variable compensation is not solely correlated to business performance. Instead the variable bonuses are determined by the performance of the individual and of the business. The firm will in the future look to set objectives against which bonuses will be considered.
This policy recognises that conflicts can arise where employees are responsible for determining the remuneration of their own business areas, however the scale of SFS means that this may be unavoidable. The CEO will be responsible for determining all remuneration packages across the company with approval for his own remuneration sought from the second director within the business.
4 POLICY STATEMENT
This policy applies to senior management and the categories of staff who would be considered to be risk takers, those engaged in control functions, those who receive remuneration packages that are aligned with those received by senior management and those whose professional activities have a material scope on SFS’s risk profile.
4.1.1 Staff Categories and business lines
The scale of SFS means that employees who hold control functions are not always independent from the business units that they oversee. They have the appropriate authority however, to take action where necessary. SFS has ensured that remuneration packages for control function employees are adequate to ensure that high quality and experienced staff are attracted and that the package is dependent on the achievement of SFS’s objectives and the objectives linked to the business areas that they control.
4.1.2 Basic Salary
Basic salary compensation is generally based upon the employee’s professional experience and organisational responsibility as set out by their job description and terms of employment.
Final approval for salary levels for all roles is the responsibility of the Board of Directors.
4.1.3 Variable Bonuses
Payment of bonuses will only be made where it is sustainable to SFS’s overall financial situation and taking into account any known future events, the performance of SFS, the business unit and the employee.
SFS will not be immediately awarding any variable remuneration that consist of shares or equivalent ownership interests at this time as the Board of Directors determined that the size and scale of SFS does not currently allow for such a strategy. As SFS grows, should it become appropriate to do so then such a scheme will be implemented.
A proportion of the variable remuneration component is not currently being deferred. SFS is aware that the requirement is that at least 40% should be deferred for a period of no less than 3 years, however at this stage of development the CEO determined that there are sufficient controls in place due to the nature of SFS reducing the risks of employees creating poor consumer outcomes or increasing SFS’s risk profile or financial resources. This will be reviewed as SFS grows.
4.1.4 Performance Based Measurements
SFS has ensured that any measurement of performance used to calculate such remuneration takes into account current and future risks as well as the cost and quantity of the capital and liquidity required. SFS has also taken into account the need for consistency with the timing and likelihood of future potential revenues incorporated into current earnings.
SFS takes into account the quality of business undertaken and services provided when assessing the performance of relevant employees.
SFS has determined that the following criteria to determine such payments will include but not be limited to;
- Individual performance against objectives
- Company performance
Where assessments of financial performance are used to calculate variable remuneration components, these will be principally based on profits, where these have been adjusted for current and future risks.
4.1.5 Pension Policy
SFS does not currently offer a pension policy to its employees. When the auto enrolment date arrives, SFS will have a workplace pension scheme in place to which it will contribute. This is anticipated to be in place by 1 April 2017.
All employees will be encouraged to invest in a pension for their future retirement.
4.1.6 Remuneration and Capital
SFS has implemented remuneration arrangements that are sufficiently flexible to allow for necessary resources being directed towards strengthening the capital base if required.
4.1.7 Early Termination
SFS has reviewed all existing contracts to ensure that any early termination payments will be payable only where they are consistent with the Remuneration Code.
This policy ensures that any payments made reflect performance achieved over time and are designed in a way that does not reward failure or misconduct.
4.2 Authorities and Ownership
This policy is owned by the CEO and is distributed to all staff within SFS. The CEO is responsible for the preparation of any decisions regarding remuneration and will take into account the long term interests of shareholders, investors and other stakeholders as well as public interest where relevant.
4.3 Policy Development, approval and implementation process
The Directors are responsible for ensuring the policy is periodically reviewed and properly implemented.
The policy is communicated to customers through the website as required.
4.4 Reporting breaches
The Remuneration Code does not contain any particular notification requirements. The FCA would expect however, to be informed where significant breaches of the Code occur and where any policies, procedures or practices would have a significant adverse impact on SFS’s reputation, services to clients or financial consequences to SFS or other firms.
4.5 Document Review Cycle
SFS’s Directors will independently review the remuneration policy on an annual basis to ensure:
- The policy operates as intended, that remuneration payments are appropriate, and that the risk profile, long term objectives and goals of SFS are adequately reflected
- The policy remains in line with the Financial Conduct Authority’s requirements, principals and standards including the continued application of proportionality under Capital Requirements Regulations (CRR)